TemplateEU DSA

DSA transparency report template fields and cadence

This outline helps scope a Digital Services Act transparency report against the harmonised EU templates, not an invented internal report format.

It separates annual Article 15 reporting, online-platform additions, VLOP/VLOSE six-month reporting, statement-of-reasons database evidence, and publication records.

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Author

Sorena AI

Published

May 9, 2026

Updated

Jul 25, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated Jul 25, 2026

Overview

The DSA should start from the official CSV/XLSX templates in Commission Implementing Regulation (EU) 2024/2835. Build one report per service, complete the quantitative and qualitative templates that apply to the service tier, publish the report in a machine-readable and easily accessible format, and keep each published version available for the required retention period.

Section 1

Applicability matrix for the template

Do not use one flat template for every service. The implementing regulation states that the reporting obligations under Articles 15, 24 and 42 are not identical, and the first column of the official templates marks which rows apply to which providers.

Complete this matrix before collecting data so teams do not add unsupported fields or omit rows that apply to their service.

All intermediary-service providers in scope of Article 15: report identification, Member State orders, applicable content-moderation information, automated-means information, and the qualitative template rows marked for all providers.
Hosting services, including online platforms: include Article 16 notice-and-action data where the official template marks the row for hosting services or online platforms.
Online platforms: add internal complaint-handling, out-of-court dispute settlement, repeat-misuse suspension, trusted-flagger, and statement-of-reasons evidence where those obligations apply.
Micro or small intermediary-service providers that are not VLOPs are treated differently under Article 15(2); record the basis for any exemption instead of publishing a blank invented report. Recommendation 2003/361/EC sets the tests at fewer than 10 staff and no more than EUR 2 million annual turnover or balance-sheet total for a microenterprise, and fewer than 50 staff and no more than EUR 10 million for a small enterprise, with partner and linked enterprises counted as required.
VLOPs and VLOSEs: apply Article 42 reporting at least every six months. Under Implementing Regulation (EU) 2024/2835, the harmonised periods are 1 January to 30 June and 1 July to 31 December; include the rows such as language-level automated-means data, moderator resources for VLOPs, and average monthly active recipients by Member State.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the use of the official CSV/XLSX templates, the different applicability rows for Articles 15, 24 and 42, and the micro or small provider distinction.

Regulation (EU) 2022/2065 (Digital Services Act)

Primary DSA legal text for Articles 15, 24 and 42 transparency reporting obligations.

European Commission - VLOPs and VLOSEs under the DSA

Commission source for the VLOP/VLOSE size threshold and enhanced DSA obligations.

Commission Recommendation 2003/361/EC on micro, small and medium-sized enterprises

Defines the staff, turnover, balance-sheet, partner-enterprise, and linked-enterprise tests used by the Article 15(2) reporting exclusion.

Section 2

Report identification and publication block

Start every service report with the identification fields from the official quantitative template. Treat these as publication metadata, not as a marketing cover page.

The publication record should be enough for a reader, auditor, or Digital Services Coordinator to tell which service, reporting period, version, and previous report the file relates to.

Name of the service provider.
Name of the service, using the same name across the CSV/XLSX file, public landing page, statement-of-reasons database account, and prior reports.
Date of publication of the report and date of publication of the latest previous report.
Starting date and ending date of the reporting period.
Version label when a prior report is corrected, with a short explanation of the changed figures, methodology, and correction date.
Public URL where the report is available, plus any accessible summary or XLSX copy if published alongside the required machine-readable file.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the report identification fields, one-report-per-service instruction, publication format, versioning, and five-year retention requirement.

European Commission - How the Digital Services Act enhances transparency online

Commission page linking DSA transparency reporting to the harmonised implementing regulation and public report accessibility.

Section 3

Cadence and retention fields

The template should contain explicit cadence fields because Article 15 reports and Article 42 reports run on different publication rhythms.

Use the official dates only where they are supported by the implementing regulation. The transition matters: the templates applied to content-moderation data collected from 1 July 2025, the first template-based period was 1 July to 31 December 2025, and the first full harmonised annual cycle for other covered providers is 1 January to 31 December 2026.

Annual DSA transparency reports for intermediary services, hosting services, and online platforms cover 1 January to 31 December once the harmonised cycle applies.
VLOPs and VLOSEs publish at least every six months for the harmonised periods 1 January to 30 June and 1 July to 31 December.
Transition record: for the 2025 transitional cycle, distinguish data before 1 July 2025 from data collected under the Annex I instructions from 1 July 2025. Do not describe 2025 as a full harmonised annual cycle.
Reports must be publicly available no later than two months after the reporting period ends.
The harmonised templates apply from 1 July 2025; the first full annual harmonised cycle for non- providers covers 1 January to 31 December 2026.
The first cycle using the harmonised templates covers 1 July to 31 December 2025.
Retain transparency reports, including all published versions, for at least five years after publication.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the reporting periods, publication deadline, template application date, transition cycles, and five-year retention period.

Regulation (EU) 2022/2065 (Digital Services Act)

Primary DSA source for annual Article 15 reporting and six-month Article 42 reporting by VLOPs and VLOSEs.

Section 4

Quantitative tables to include

Use the official quantitative template sections as the spine of the report. Each table should keep the official applicability, service, reporting period, indicator, scope, value, and contextual-information logic so figures remain comparable across services.

Where a row applies and the result is zero, enter 0. Where the row cannot apply to the provider or service, leave it blank rather than forcing an invented zero.

Member State orders to act against illegal content: category of illegal content, Member State scope, number of orders, number of specific items, median time to acknowledge receipt, and median time to give effect.
Member State orders to provide information: category, Member State scope, number of orders, median acknowledgement time, and median time to give effect.
Article 16 notices: number of notices, trusted-flagger notices, number of specific items, action basis, automated processing, and median time to take action.
Own-initiative content moderation: number and type of measures affecting availability, visibility, accessibility, user ability to provide information, or monetisation, broken down by detection method and restriction type where required.
Online-platform redress: internal complaint-handling outcomes, out-of-court dispute settlement outcomes, implemented decisions, and suspensions for repeat misuse under the platform rows.
Automated means: number of measures or notices processed using automated means and indicators such as accuracy, precision, recall, and possible error rate where the official row applies.
additions: content-moderation human resources and linguistic expertise for VLOPs, and average monthly active recipients by Member State for VLOPs and VLOSEs.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the quantitative template sections for orders, notices, own-initiative moderation, complaints, out-of-court disputes, automated means, moderator resources, and active-recipient reporting.

European Commission - DSA guidance on publishing user numbers

Commission guidance supporting the active-recipient data point used for VLOP/VLOSE identification and reporting.

Section 5

Qualitative narrative fields

The qualitative template should explain how the numbers were produced and what the moderation system did during the reporting period. It is not a substitute for the quantitative CSV/XLSX tables.

Keep qualitative text tied to the official indicators. Avoid adding generic policy statements that do not explain the reporting period, the service, or the measurement method.

Summary of content moderation engaged in at the provider's own initiative.
Meaningful and comprehensible information about own-initiative content moderation, including the policies, detection sources, and restriction types reflected in the quantitative rows.
Qualitative description of automated means used for content moderation.
Description of the indicators of accuracy and possible rate of error for automated means.
Specification of the precise purposes for which automated means are applied.
Safeguards applied to the use of automated means.
High-level description of the content-moderation governance structure.
For VLOPs where applicable: qualifications, training, support, and methodology for computing human resources dedicated to content moderation.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the qualitative template indicators and the instruction that omitting required template parts without a specific objective reason makes the report incomplete.

Section 6

Statement-of-reasons and DSA Transparency Database evidence

A transparency report is not the same as the DSA Transparency Database submission process, but the two datasets should reconcile for online platforms covered by Article 24(5). Article 17 explain individual moderation restrictions to users, while Article 24(5) requires covered online platforms to send those statements to the Commission database; Article 19 can exclude qualifying micro and small providers from that platform-section duty.

Use the database as supporting evidence for online-platform reporting, especially for moderation restrictions, grounds, automated processing, free-text explanation fields, and the difference between public database data and internal source-of-record artifacts.

Keep a reconciliation table with report section, internal moderation-event source, statement-of-reasons submission count, DSA Transparency Database field, and variance explanation.
Do not include personal data in public database submissions; the Commission FAQ says providers must remove personal data before publication in the database.
Do not treat the database as a repository of the moderated content itself; it records and accompanying decision information, not the underlying content.
Account for database retention limits when preserving evidence: search data is retained for six months, daily CSV dumps for 18 months, and dashboard aggregates for five years according to the Commission FAQ.
For large data extracts, record whether evidence came from full or light daily archives because light archives omit certain long free-text attributes and territorial scope.

Sources for this answer

European Commission - DSA Transparency Database Q&A

Supports the distinction between Article 17 statements of reasons, Article 24(5) database submissions, public database access, personal-data removal, and database retention periods.

Regulation (EU) 2022/2065 (Digital Services Act)

Primary DSA source for Article 17 statement-of-reasons requirements and Article 24 platform transparency obligations.

Section 7

Evidence tables to keep behind the public report

The public report should stay aligned with the official template. Keep operational evidence in supporting tables so reviewers can reproduce the figures without adding unofficial fields to the published CSV.

Each evidence table should identify the source system, extraction time, aggregation rule, owner, and reconciliation status for the official template row it supports.

Orders evidence table: order identifier, issuing Member State, legal basis or category, received timestamp, acknowledgement timestamp, action timestamp, item count, source queue, and report row.
Notice-and-action evidence table: notice identifier, notifier type, trusted-flagger status, item count, alleged illegality category, action basis, action timestamp, automation flag, and report row.
Own-initiative moderation evidence table: detection source, policy or law ground, restriction type, affected item count, user-notification status, statement-of-reasons link where applicable, and report row.
Complaints and dispute evidence table: complaint or dispute type, original decision, outcome, reversal status, median-time source, implementation status for out-of-court decisions, and report row.
Automated-means evidence table: tool name, precise purpose, measure or notice population, human-review rule, accuracy metric source, precision/recall source, error-rate explanation, safeguard, and report row.
evidence table: designation status, active-recipient calculation source, Member State breakdown, and report row; for VLOPs, also include the moderator headcount source, language expertise method, and CEFR-B2 evidence for linguistic expertise.
Publication evidence table: public URL, CSV encoding check, XLSX copy if used, publication date, previous-report date, version label, correction note, retention review date, and source owner.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the evidence categories by specifying the official rows, measurement units, CSV/UTF-8 requirements, contextual-information columns, zero-versus-blank treatment, and versioning expectations.

European Commission - DSA Transparency Database Q&A

Supports keeping source evidence for statements-of-reasons submissions, database downloads, light versus full archives, and retention limitations.

Section 8

Pre-publication checks

Before publication, check the report against the official template instead of against an internal checklist alone. The strongest review asks whether every required official row is complete, blank for a valid reason, or zero because the practice could have occurred but did not.

Keep the review short and reproducible so later corrected versions can explain exactly what changed.

The service tier is documented and every official applicability row has been assessed.
The quantitative and qualitative templates are both present, or any omission has a specific and objective reason.
Counts are integers, percentages are floating values in the 0 to 1 interval, and median times are stated in hours.
Rows that apply but produced no activity use 0; rows that cannot apply to the service are blank.
Illegal-content and incompatible-content categories reconcile to the official category logic and do not use provider-created high-level categories.
The public file is , UTF-8 encoded, and made easily accessible; any XLSX or narrative summary is supplementary.
All public versions remain available for at least five years and corrected versions are explicitly marked.

Sources for this answer

Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates

Supports the validation checks for completeness, formats, units, category handling, zero-versus-blank treatment, and retention.

Recommended next step

Turn DSA reporting rows into evidence-backed tables

Sorena can help map your service tier, reporting period, official CSV/XLSX rows, statement-of-reasons evidence, and publication records into a reviewable DSA transparency-report package.

Research workflow

Open Research Copilot for DSA reporting

Ask questions tied to cited sources about Article 15, Article 24, Article 42, statement-of-reasons data, and the harmonised reporting templates.

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Talk to Sorena

Review the reporting template

Check which DSA transparency-report rows apply to your service tier and which evidence tables are needed before publication.

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Primary sources